On July 10, 2018, Infernal Technology and Terminal Reality (Infernal) filed a lawsuit in the Eastern District of Texas alleging that Crytek GmbH (Crytek) infringed upon U.S. Patent Nos. 6,362,822 (the ‘822 Patent) and 7,061,488 (the ‘488 Patent). The two patents relate to lighting and shadowing methods in computer graphic simulations.

Image from the ‘822 Patent, Fig. 2.

Claim 1 of the ‘822 Patent reads:

A shadow rendering method for use in a computer system, the method comprising the steps of:

providing observer data of a simulated multi-dimensional scene;

providing lighting data associated with a plurality of simulated light sources arranged to illuminate said scene, said lighting data including light image data;

for each of said plurality of light sources, comparing at least a portion of said observer data with at least a portion of said light data to determine if a modeled point within storing at least a portion of said light image data associated with said point and said light source in a light accumulation buffer; and then

combining at least a portion of said light accumulation buffer with said observer data; and

Infernal claims that Crytek’s utilization of video game engine “CryEngine” allegedly infringes the asserted patents. According to the Complaint, Crytek used the allegedly infringing game engine to develop the Crysis series, Warface, Ryse: Son of Rome, The Climb, and Robinson: The Journey.

Typically, the next step for a defendant in this situation is to petition the Patent Trial and Appeal Board (PTAB) for an Inter Partes Review (IPR), but the ‘822 and ‘488 Patents have already survived an IPR because of earlier litigation. In 2015, Infernal sued Electronic Arts for patent infringement. EA responded by petitioning the PTAB for an IPR; however, the PTAB found the ‘822 and ‘488 Patents to be “Not Unpatentable.” EA settled the lawsuit after the PTAB’s decision. Crytek can still petition for an IPR of the asserted patents, but will likely have to use different prior art that the art used by EA or provide a good reason why the Board got it wrong the first time around.

If this seems like deja vu that is because Infernal filed complaints similar to the Crytek Complaint against Microsoft in April and against Activision Blizzard in May. To read our blog post on the Microsoft case click here. We will continue to monitor all three of these cases and provide updates when possible.

Salt Lake City, Utah. June 2, 2016. U.S. District Judge Jill N. Parrish granted Electronic Arts Inc.’s motion to dismiss, saying that Utah-based White Knuckle Gaming LLC cannot sue for patent infringement because the patent at issue — which describes a method for updating sports videos games to reflect real-world changes like statistics, athlete appearances and uniforms — covers an abstract idea and does not include any additional elements that transform the claim into patent-eligible material.

“The patent claims do nothing more than recite the performance of a long-established business practice — rewriting software to produce an updated version — using a general purpose computer and the internet,” Judge Parrish wrote.

“It is a longstanding business practice in the video game industry to update sports video games parameters to reflect real-world developments,” Judge Parrish wrote.

According to Judge Parrish, the patent doesn’t have any additional elements that transforms the abstract idea into an inventive concept because it doesn’t rely on anything other than generic computer equipment in order to be accomplished.

“The court holds that the patent is drawn to a patent-ineligible abstract idea, and merely requiring generic computer implementation fails to transform that idea into a patent-eligible invention,” Judge Parrish wrote.

The patent-in-suit is U.S. Patent Number 8,540,575 titled “Method and System for Increased Realism in Video Games.” One interesting thing about this case is the length of the claims that were invalidated. For example, representative claim 1 reads:

1. A game medium configured to provide a sports video game in conjunction with a video game machine, the sports video game including video game rules and video game character parameters, the video game character parameters including video game character performance parameters associated with individual video game characters, the game medium being configured to cause the video game machine to perform a method comprising:

loading video game data stored by the game medium into a random access memory of the video game machine for playing the video game, the video game data including the video game rules and a particular video game character performance parameter associated with a particular individual video game character associated with a particular real-life sports athlete, wherein the particular video game performance parameter is based at least in part on a real-life performance of the particular real-life sports athlete playing in one or more real-life sporting events, the particular video game character performance parameter affecting the manner in which the particular individual video game character performs in the sports video game;

during a single sports season, receiving a series of updated video game character performance parameters from a data server via a network including the Internet, wherein each of the updated video game character performance parameters in the series is based at least in part on one or more different real-life performances of the particular real-life sports athlete in one or more sporting events performed during the single sports season;

updating the sports video game with each of the updated video game character performance parameters received, wherein each update changes the manner in which the particular individual video game character performs in the sports video game such that the particular individual video game character more closely simulates real-life performance attributes of the particular real-life athlete in the sports video game; and

enabling a user to control the particular individual video game character in the sports video game using a video game controller connected to the video game machine.

This is a case that will be closely and heavily scrutinized in the wake of Alice v. CLS Bank. Many practitioners will use this case as more fodder to try to read the tea leaves in the winds of change that is Federal jurisprudence on patent-eligible subject matter.

White Knuckle Gaming will likely appeal. Along with the McRO case currently pending at the Federal Circuit, this could be another pertinent case in the world of video game patents.

On March 30, 2015, Acceleration Bay filed suit against Electronic Arts for the alleged infringement of six of its multiplayer video game patents. The patents-in-suit are: U.S. Patent Nos. 6,701,344; 6,714,966; 6,732,147; 6,829,634; 6,910,069; and 6,920,497. These patents read on interacting with broadcast channels to allow individual players to connect with other players and communicate with them throughout the game by using a multiplayer mode.

On June 18, 2015, EA filed a reply brief in support of its Motion to Dismiss. There has been no ruling on the Motion to Dismiss thus far.

This case was terminated on April 8, 2014, following a settlement conference. All claims and counterclaims were dismissed with prejudice between Plaintiff Gametek LLC and Defendant Big Viking Games, Inc.

Gametek filed suit against 21 companies including Facebook, Electronic Arts, and Zynga. Gametek alleged the companies infringed its patent for virtual currency and payment system incorporating items bought and used in-game. Gametek sought damages and injunction through this lawsuit. The patent-in-suit was U.S. Patent 7,076,445.

Oral Arguments pending at the Court of Appeals
for the Federal Circuit

Filed October
27, 2014

Case No. 15-1080

This case was submitted by plaintiff McRo, Inc. to the Court of Appeals for the Federal Circuit following the decision in favor of defendants. Some of the defendants include Bandai Namco Games America Inc., Sega of America Inc., and Electronic Arts Inc. Oral arguments are this Friday, December 11, 2015.The case was originally filed in the United States District Court for the Central District of California (case no. 2:12-cv-10322), on December 4, 2012. The patents-in-suit, 6,307,576 and 6,611,278, are entitled, “Method for Automatically Animating Lip Synchronization and Facial Expression of Animated Characters.”

obtaining a first set of
rules that defines a morph weight set stream as a function of phoneme sequence
and times associated with said phoneme sequence;

obtaining a plurality of
sub-sequences of timed phonemes corresponding to a desired audio sequence for
said three-dimensional characters;

generating an output morph
weight set stream by applying said first set of rules to each sub-sequence of
said plurality of sub-sequences of timed phonemes; and

applying said output morph
weight set stream to an input sequence of animated characters to generate an
output sequence of animated characters with lip and facial expression
synchronized to said audio sequence.

McRO
alleged defendant Bandai infringed the patents-in-suit by using the
claimed methods for automatically animating lip synchronization of
three-dimensional characters.

The
defendants argued McRO’s lip-sync animation patents claimed only an abstract
idea under the U.S. Supreme Court’s recent Alice decision, and therefore the
patents are invalid. McRO argued in the appeals court that the patents-in-suit
were not invalid under the Alice case. McRO stated its patents claim a
3-dimensional lip-sync animation. McRO argued that the steps in the patent
should be taken as a whole to determine patentability, rather than
individually.

The
Alice case held that a patent is valid if the invention improves existing
technological processes.We will be attending oral arguments at the court, and will report any significant updates.

Back in January we reported a new patent case filed by White Knuckle IP against Electronic Arts over updating sports video games based on real-life events during a season. The asserted patent was U.S. Pat. No. 8,529,350. That case was actually terminated and refiled as Utah District case no. 1-15-cv-00036 in February.

From our earlier report, the patent discusses how prior art games were fixed as of the day they were released. A real-life player’s outstanding performance or a major trade taking place during the season would not be reflected until the next version of the game was released. The system described in the ‘350 patent purports to solve this problem by downloading updates to game attributes that are based on real-life changes in players, teams, and venues.

EA filed an inter partes review (IPR) request yesterday with the USPTO to invalidate the patent (IPR2015-01595). EA argues that the ‘350 patent should be limited to updates applied to stadium or field parameters based on arguments made by the patentee during prosecution. Moreover, EA argues that their own earlier games teach all the features claimed in the ‘350 patent. EA points to the 2001 iteration of their popular FIFA soccer games and the 2000 version of their Madden football games as teaching the updating features claimed in the ‘350 patent. Of note is that one of the references cited by EA is a Madden 2000 Updates Website which included a “Playoff Week 1 Update” file.

At this time, the IPR has only been filed with the USPTO. The Patent Trials and Appeals Board (PTAB) will consider whether to institute the IPR based on EA’s arguments. If the PTAB institutes the IPR, EA and White Knuckle will fight it out at the USPTO rather than (or in addition to) the federal courthouse in Utah.

Brown v. Electronic Arts, Inc.
United States District Court for the Central District of California
Case No. 2:09-cv-01598

&

In re: NCAA Student-Athlete Name & Likeness Licensing Litigation (Keller, et al v. Electronic Arts, Inc.)
United States District Court for the Northern District of California
Case No. 4:09-cv-01967

On July 31, 2013, the Ninth Circuit Court of Appeals filed opinions in two separate, yet similar, cases involving Electronic Arts (“EA”) and two of its popular football franchises, Madden NFL and NCAA Football. In the first case, former NFL player Jim Brown (widely regarded as one of the best NFL players of all time) filed suit against EA claiming that its use of his likeness in its Madden NFL franchise violated §43 (a) of the Lanham Act (KEY POINT: The Brown case, as decided, is based on the Lanham Act). Keller’s case, meanwhile, was a putative claim brought against EA claiming that the popular NCAA Football franchise violated his (and others in the class) right of publicity under California Civil Code §3344 and California common law (as opposed to the Lanham Act). At first blush, these cases seem quite similar, yet the results were drastically different. In Brown, the Court found that EA’s use of Brown’s likeness was protected under the First Amendment. However, in Keller the Court ruled that EA could not defend on First Amendment grounds and denied EA’s motion to dismiss. This all depends on whether the alleged infringing content is a trademark under the Lanham Act, or an individual’s Right of Publicity. When analyzing an infringement claim under the Lanham Act, courts primarily apply the Rogers test which focuses on the artistic relevance of the trademark (or in this case, likeness) in relation to the creative work. Conversely, a right of publicity claim tends to be evaluated using the transformative use test which places a heightened burden on a content creator to show that a person’s likeness is incidental to the overall work.

Why such different results?
One might except two cases arising from nearly identical facts to have similar results, but the choice of claims is what dictated the tests applied and the differing results. The Ninth Circuit looked to Brown v. Entertainment Merchants Ass’n to establish that videogames are protected under the First Amendment as expressive works because they, “communicate ideas—and even social messages—through many familiar literary devices (such as characters, dialogue, plot, and music) and through features distinctive to the medium (such as the player’s interaction with the virtual world).” Using this as a basis, the Court ruled that a §43 (a) Lanham Act claim fell within the Rogers test established by the California Supreme Court. The Rogers test, established in Rogers v. Grimaldi, 875 F.2d 994 (2d Cir. 1989), is essentially a balancing test that seeks to weigh, “the public’s First Amendment interest in free expression against the public’s interest in being free from consumer confusion about affiliation and endorsement.” The Rogers test limits application of §43 (a) to expressive works, [U]nless [the use of the trademark or other identifying material] has no artistic relevance to the underlying work whatsoever, or, if it has some artistic relevance, unless the [use of trademark or other identifying material] explicitly misleads as to the source or the content of the work.

In evaluating Brown’s suit against EA, the district court granted EA’s motion for summary judgment on grounds that Brown had not alleged sufficient facts to satisfy either condition of the Rogers test. In order to be “artistically relevant” under the Rogers test, the trademark (or in this case a person’s likeness) must merely be “above zero”. The court reasoned that because EA prides itself, and the Madden series in particular, on its expressive goals of realism that Brown’s likeness has, “at least some artistic relevance to EA’s work.” The Court then looked to the second prong of the Rogers test and found Brown’s argument lacking. Under the second prong, a claimant must show that a defendant was explicitly misleading consumers as to “the source or the content of the work.” In this case, EA did not explicitly mislead consumers. Although Brown is a famous NFL player, it is highly unlikely that any players of the Madden series would believe that he was “somehow behind [the game] or that [he] sponsors [EA’s] product,” because he is only one out of many stars included in the game. While there may be some consumers who are mislead, their confusion cannot be attributed to an explicit representation by EA and therefore Brown’s claim does not satisfy this facet of the test.

Had Keller and the other parties to the class action suit brought claims under the Lanham Act, the result would have been similar. However, because Keller involved claims of statutory and common law infringement of rights of publicity, the Ninth Circuit applied another test altogether. EA attempted to defend on the basis of First Amendment freedom of speech via a motion to strike under California’s Anti-SLAPP statute. In order to prevail under the Anti-SLAPP statute the party asserting the defense must first make a prima facie showing that the suit arises from an act made by the defendant in connection with a public issue in furtherance of the person’s “right of petition or free speech under the United States Constitution or the California Constitution.” It is uncontested that EA’s Madden series satisfies this requirement in light of Brown v. Entertainment Merchants Ass’n. However, the Court denied the motion to strike because EA did not satisfy the second requirement which requires the defendant have a likelihood of success on the merits. The reasoning for this was that under the transformative use test, the Court believed that Keller had a legitimate claim against EA.

Under the transformative use test, the California Supreme Court outlined five factors which should be taken into account when assessing whether a claimant’s right of publicity has been violated. These five considerations are whether: (1) the celebrity likeness is one of the raw materials from which an original work is synthesized; (2) the work is primarily the defendant’s own expression if the expression is something other than the likeness of the celebrity; (3) the literal and imitative or creative elements predominate in the work; (4) the marketability and economic value of the challenged work derives primarily from the fame of the celebrity depicted; and (5) an artist’s skill and talent has been manifestly subordinated to the overall goal of creating a conventional portrait of a celebrity so as to commercially exploit the celebrity’s fame. The Ninth Circuit focused predominantly on No Doubt v. Activision Publishing to establish that EA’s use of Keller’s (and the other members of the class) likeness was not a transformative use. Specifically, the Ninth Circuit reasoned that, like in No Doubt, EA represented Keller as, “what he was: the starting quarterback for Arizona State and Nebraska, and the game’s setting is identical to where the public found [Keller] during his collegiate career: on the football field.” The focus on realism relied upon in Brown v. EA ended up being to EA’s detriment in Keller under the transformative use test. Unlike the Rogers test that requires artistic relevance to only be “above zero”, the transformative use test requires a defendant to go further and create a work that is more than just a direct copy of a real-life person. EA did argue that the Rogers test should be applied in this case as well. The court, however, denied this argument reasoning that the Lanham Act and the Rogers test are in place to protect consumers from confusion, but the right of publicity is in place to protect the celebrity.

What is the effect on the games industry?
Both of these decisions have significant repercussions for the gaming industry. The Madden and NCAA franchises have long provided EA with predictable returns on their investment on a year-to-year basis, the increase in litigation is beginning to prove more trouble than it’s worth for EA’s partners. Last month, the NCAA announced that due to “the current business climate and costs of litigation” it would not be renewing its contract with EA which is set to expire in June 2014. However, this could affect more than just EA. The Keller decision in particular opens the door to litigation if any celebrity’s likeness is utilized. While parody exceptions will still likely cover most games that choose to employ a celebrity’s likeness, this case sets precedent for potential legal woes. More than that, the Keller decision in particular is a blow to game developers in that it is the first restriction on the First Amendment protections to come out of Brown v. Entertainment Merchants Ass’n.

As always, we will monitor this case for new developments and update accordingly.

This
trademark dispute arises out of Electronic Arts popular first-person shooter
series, Battlefield. Specifically, EA sought declaratory judgment
stating that the game (which uses vehicles modeled after Textron’s AH-1Z,
UH-1Y, and V-22 helicopters) did not infringe upon Textron’s trademarks. However, before reaching a trial, the case
was dismissed with prejudice in the wake of an out-of-court settlement
agreement in early-mid 2013.

In re: NCAA Student-Athlete Name & Likeness Licensing Litigation
U.S. District Court for the Northern District of California
Case Number: 4:09-cv-01967

On Thursday, June 21, 2013, a group of current and former NCAA athletes sought class action status from a California federal judge. They allege that the NCAA violated anti-trust laws (as well as their right of publicity) by using their names and likenesses in television broadcasts and videogames without providing any form of compensation. District Court Judge Claudia Wilken asked attorneys for the plaintiffs to, “disprove the NCAA’s arguments that the players” had different levels of ability and fame which would create a conflict within the class. Attorneys for the NCAA also alleged that class status could not be granted in regards to broadcasts because the broadcasts do not feature every athlete on a team’s roster.

Michael D. Hausfeld (of Hausfeld LLP) argued that the first argument was invalid because student athletes receive the same scholarships regardless of ability, and compensation from broadcasts could be distributed equally in the same manner. Hausfeld stated, “[d]istributing revenue from the conveyance of image and likeness, would correlate to that fairness principle by maintaining the equality of all the athletes.” Furthermore, it would not be difficult to establish which athletes appear in the broadcasts because in other industries there are those who keep track of appearances. Gregory Curtner (of Schiff Hardin), arguing on behalf of the NCAA, stated it would be an arduous task, and that, “[a]scertainability is a big issue and [the plaintiffs] have no solution for it.” Counsel for the players goes on to argue that the NCAA, by requiring players to participate as amateurs and prohibiting them from being compensated, for a, “horizontal agreement to not compete.”

The various lawsuits name the NCAA, game publisher EA Sports, and Collegiate Licensing Co. (a trademark licensing and marketing company). Trial is currently scheduled for February 2014. This case could be significant for EA because the NCAA players are seeking injunctive relief to prevent EA from continuing to make its NCAA series without providing compensation. In the event that this happens, EA will need to decide whether to continue making its NCAA franchise without using the likenesses of current players to market the game, or start paying a new license fee.

On Friday,
June 21, 2013, a one-week trial culminated in a jury finding that Robin
Antonick (the programmer for the original “Madden NFL” game released
in the late 1980s) was not barred from suing for millions in royalties by the
statute of limitations.

Back in
1988, Antonick was responsible for programming the first iteration of
Electronic Arts Madden NFL series for
the Apple II. Antonick alleges that EA
owes him royalties stemming from their Madden
NFL game released on the Sega Genesis.
The jury, specifically, found that Antonick did not become aware of EA’s
alleged breach until 2009 at EA’s 20th anniversary celebration of the
franchise. Whereas Antonick’s version of
the game took four years to make, multiple EA employees involved with the
franchise reminisced how the Sega version only took six months to make, even
though none of the lead developers had ever created a videogame before. Antonick alleges that he then began to
realize that there was no way the game could have been developed in that amount
of time without relying on the source code he wrote. Leonard Aragon, Antonick’s attorney, goes on
to allege that the Sega version of the game used a football field 80 yards
wide, whereas a typical field is 53 yards wide.
This is significant because, in Antonick’s original game, the field was
80 yards wide, and there is, “no reason to have it that size unless you
take it from the previous game; [because] if you put [Antonick’s] plays on a
53-yard field half the team would be off the field.” Electronic Arts alleges that Antonick could
have discovered this information back in 2004 when the publisher was celebrating
the franchise’s 15th anniversary.

Trial is
scheduled to being on July 1, 2013, to determine if, and to what extent, EA owes
royalties to Antonick. The verdict could
be substantial. Under the original contract, EA agreed to pay Antonick royalties
on any works that are either derivative of the original 1988 game or any other
works stemming from those derivative works.

The suit filed last year by EA for copyright infringement—as
well as Zynga’s counterclaims—has been dismissed following an out-of-court
settlement in February 2013. Zynga
released a statement saying, “EA and Zynga have resolved their respective
claims and have reached a settlement of their litigation in the Northern
District of California.” All claims
were dismissed with prejudice. Gamasutra
claims it has a source familiar with the matter than informed them that,
“Zynga is ‘pleased’ with the nature of the settlement.”We’re closing the books on this one.

An order was issued by a district court judge in the
Northern District of California on May 30, 2013, dismissing the case with prejudice after the
parties came to an outside settlement.
Pecover and Owens v. Electronic Arts, Inc. was a class action suit
initially filed claiming that EA had a monopoly on all football games due to
its exclusive licenses with the NFL, NCAA, and Arena Football League (AFL). The court’s modification of the settlement’s
Plan of Allocation granted the lead class members $5,000, their attorneys
received fees in the amount of $7.29 million, as well as a $2 million dollar
reimbursement for costs. Furthermore,
the order granted class members who filed a valid claim form no later than May
15, 2013, the right to up to $162.96.
The settlement also stipulated that EA is unable to renew its NCAA and
Collegiate Licensing Co. football licenses for a period of five years after
their expiration in 2014. EA is also
barred from obtaining exclusive AFL licenses for a period of five years from
the date of the order. However, EA’s
exclusive license with the NFL—the basis of its massively successful Madden NFL series—was not affected.

This case was recently remanded to the United States District Court for
the District of New Jersey by the Third Circuit Court of Appeals after the Court of
Appeals held that the grant of summary judgment was in error and that further
proceedings were necessary. The case
arises from Plaintiff Ryan Hart (individually and on behalf of all others
similarly situated) alleging that Electronics Arts (EA) NCAA Football series of games violated his right of publicity by
appropriating his likeness in NCAA
Football 2004, 2005,and 2006. Hart was a successful quarterback for Rutgers
University from 2002 through the 2005 season, taking his team to their first
Bowl game since 1978. The case was
originally dismissed after EA filed a motion for summary judgment; the district
court held that EA NCAA games were
protected under the First Amendment.

The Third Circuit, in determining that the District Court erred
conducted a balancing test when coming to its decision to decide whether
First Amendment rights superseded the right of publicity. In conducting this analysis, the court looked
to three tests: the predominant use test, the Rogers test, and the transformative use test. The predominant use test maintains that,
“If a product is being sold that predominantly exploits the commercial
value of an individual’s identity, that product should be held to violate the
right of publicity and not be protected by the First Amendment.” The court did not, however, that if the
predominant purpose is to comment on or about a celebrity (such as parody) more
weight would be given to the expressive values.
The court ultimately declined this test stating that at best is was very
subjective, but at worst is was arbitrary forcing judges to not only be,
“impartial jurists” but also, “discerning art
critics.” The court then turned to
the Rogers Test from Rogers v. Grimaldi. This test relies on a theory of trademark
law, specifically false endorsement, and it holds that the use of celebrity
likeness is acceptable as long as it is not simply, “a disguised
commercial advertisement for the sale of goods and services”. The court also rejected this test stating
that it would be unwise to determine that Hart was unable to retain his right
of publicity because his likeness was being used in the very same arena from
which it was derived. The court reasoned
that it made sense that any use of Hart’s likeness would be in a football
setting since that is where his celebrity came from. After rejecting the predominant use and Rogers test, the court adopted the
transformative use test. This test
requires that an artist adopting the likeness of another must contribute
something more than a “merely trivial” variation to be protected
under the First Amendment. However, the
threshold to meet this test is rather low, a work is transformative if it adds
“new expression”. That alone
is sufficient to fall within the boundaries of the transformative use
test. Ultimately, the Court of Appeals
decided that NCAA Football was not
sufficiently transformative to attain First Amendment protection because it
adds nothing creative to Hart’s likeness.
EA argued that all player avatars could be customized, therefore
satisfying the transformation requirement.
However, the court held that the main appeal of Hart’s likeness was
maintaining it as is so that fans could play as him. Furthermore, any customization was not a
transformation of Hart’s likeness allowing the use, but was instead a new
creative product that caused the use to cease to exist.

This case is still pending in the District Court of New Jersey after the
Third Circuit’s opinion was filed on May 21, 2013. If, after further proceedings, the District Court
determines that Hart’s right to publicity was affected, it could have a
substantial effect on EA NCAA
series. Because NCAA athletes cannot
receive compensation that in any way relates to their athleticism, it is
unlikely that players would sign away their likenesses to EA as there is little
benefit to be gained. This would make
the game series a potentially huge liability for the company, putting them in a
position that would require they either risk litigation or lose the
distinctiveness of the athletes that fans of the series purchase the game for.

We will continue to monitor this case and provide any relevant updates
as they become available.

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The information on this site is provided for informative and educational use only and should not be relied on as legal advice. No attorney-client relationship exists by virtue of you reading our blog. Always consult an attorney if you need specific legal guidance.